-44- additional facilities if petitioner increased its herd to 7,500 cows. We disagree. The existing facilities (including a milking parlor that could accommodate 10,000 cows) needed to be modernized or replaced, and petitioner planned to expand its herd to 9,000 cows. Respondent argues that most of the capital assets petitioner bought during the years in issue were items that petitioner bought each year, such as trucks, loaders, and refrigerators, and were not assets bought as part of a capital expansion program. Respondent argues that petitioner incorrectly counted this need for funds both in its working capital calculations and in the capital improvements category. We need not decide whether petitioner included this need for funds both in the capital improvements category and in the working capital category because we have not separately considered petitioner's working capital needs. Petitioner's category one and two expenses projected for equipment and construction were generally less than its actual expenses for those purposes during those periods. Actual expenses in category one exceeded projected expenses by $305,043 for 1987, $2,335 for 1988, and $447,859 for 1989. In category two, actual expenses exceeded projected expenses by $355,194 forPage: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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